- 3 - limitations on assessment bars respondent’s determinations for each year at issue. FINDINGS OF FACT Some of the facts have been stipulated and are so found. We incorporate by this reference the stipulation of facts, supplemental stipulation of facts, and attached exhibits. Petitioners Manuel Karcho and Margaret Karcho are husband and wife who resided in Southfield, Michigan, at the time they filed their petition. Petitioners filed joint returns for the years in issue. Mr. Karcho had emigrated from Iran at age 12 and had very little formal education. Mrs. Karcho, who emigrated from Malta at age 11, completed a high school education in the United States and during the years in issue was employed as a membership and billing system analyst for a health insurance provider. During the years in issue Mr. Karcho, through his wholly owned S corporation, Banner Amusement Enterprises, Inc. (Banner), owned and operated an amusement arcade called the Space Station. Mr. Karcho had previously been employed as a manager of the Space Station before purchasing all of the stock of Banner in 1985 for $25,000 in cash and a $25,000 note to the seller. Mr. Karcho continued to manage the operations of the arcade during the years in issue, with some part-time help. The arcade was open 7 days a week.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011